Three-judge federal panel upholds Civil Rights Act Title II under Commerce Clause and certifies case directly to the Supreme Court

A three-judge U.S. District Court panel for the Northern District of Georgia upheld Title II of the Civil Rights Act on July 22, 1964, ruling that racial discrimination by hotels and restaurants substantially affected interstate commerce — establishing the constitutional test that the Supreme Court would ultimately apply. The panel directly certified the case to the Supreme Court under a statutory procedure for expedited review of constitutional challenges to federal law, ensuring a decision before the end of the 1964-65 term. The companion case, Katzenbach v. McClung, involving Ollie's Barbecue in Birmingham, Alabama, was certified at the same time and consolidated for argument.